Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:25-cv-02179
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Villarreal, Judge Hamilton dismissed the cases with prejudice after finding no imminent danger and identifying procedural bars.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice; the named federal and state judges and other officials were defendants in those cases.
What happened
Bonilla v. Judge Lydia Villarreal et al. involved multiple nearly identical civil-rights complaints filed by Steven Wayne Bonilla, a state prisoner representing himself. He sued various federal and state judges and other officials over his conviction and the handling of his cases.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred under several legal rules even if he could proceed without paying those fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was ordered to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Alameda County Superior Court · No. 4:25-cv-02179
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The order covers the related cases listed under case numbers 25-cv-1979-PJH, 25-cv-1980-PJH, 25-cv-2063-PJH, 25-cv-2064-PJH, 25-cv-2065-PJH, 25-cv-2178-PJH, 25-cv-2179-PJH, 25-cv-2180-PJH, 25-cv-2182-PJH, 25-cv-2183-PJH, 25-cv-2184-PJH, 25-cv-2444-PJH, 25-cv-2445-PJH, 25-cv-2513-PJH, 25-cv-2532-PJH, 25-cv-2533-PJH, 25-cv-2535-PJH, 25-cv-2536-PJH, 25-cv-2537-PJH, 25-cv-2538-PJH, 25-cv-2539-PJH, 25-cv-2540-PJH, 25-cv-2617-PJH, 25-cv-2618-PJH, 25-cv-2621-PJH, and 25-cv-2629-PJH.
Bonilla named various federal and state judges and other officials as defendants. The order says he sought relief concerning his underlying conviction or the way his other state and federal court cases had been handled. The court also noted that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state proceedings.
Court’s Analysis
The court addressed Bonilla’s requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying fees may do so only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such danger.
The court further stated that, even if Bonilla’s request to proceed without paying fees were granted, the lawsuits would be barred under rules or doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not separately explain how each cited rule applied to each case. It also stated that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the judge’s impartiality.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
Classification Note
This is a procedural order. The court dismissed the cases based on the filing-fee restriction and stated procedural bars without deciding the underlying civil-rights claims on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.